Schwab’s trust architecture — move the value, keep the control
Transfers as a shape, not as the benefit people imagineThe Canadian analogue is an estate freeze into a holdco with a family trust holding the growth shares. It still earns its keep for creditor protection, for succession, and for multiplying the lifetime capital gains exemption across family members on a future sale.
But two hard edges, both of which get glossed over in the planning literature. The income-splitting benefit most people are picturing was largely removed by the TOSI rules in 2018. And every family trust faces a deemed disposition of its capital property on its 21st anniversary — a real, dated liability that arrives whether or not anyone has planned for it. If a freeze is done, that date goes in the calendar the same day the trust is settled.